Expert Analysis

Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds

Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Carlos Serrano Palacio and Szymon Wlazlowski of Deloitte examine how transfer pricing complexities arise in special purpose vehicle investments and outline key considerations in navigating their unique risk, substance, and valuation challenges

Łukasz Kumkowski of MDDP explains Poland’s GloBE reporting rules, deadlines, and the option to apply the provisions retroactively from 2024, highlighting how multinational groups should prepare for their first filings

Jeklira Tampubolon and Dwipa Abimanyu Dewantara of GNV Consulting outline recent developments on import duties, the Directorate General of Taxes’ follow-up on concrete tax data, e-commerce taxation, and free trade zone regulations

The Italian framework for tax certainty has been reinforced through advance pricing agreements, mutual agreement procedures, and other dispute resolution tools, explain Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente